On August 13, Advocacy submitted comments supporting EPA’s December 2008 final rule, which would allow exclusion of certain hazardous materials from the hazardous waste requirements under the Resource Conservation and Recovery Act (RCRA). This regulatory relief has been sought by the small business community for over 20 years. This issue was among the top ten regulatory reform items in Advocacy’s r3 initiative.
Our comments affirm the soundness of EPA’s judgment in the final rule, which will help small businesses and allow responsible recycling in lieu of requiring disposal. In our view, the rule is carefully tailored to address the hazards of recycling, and therefore EPA expects no net harm to the environment or public health.
— Kevin Bromberg, Assistant Chief Counsel